Mehtods and systems for real-time identification and mitigation of agent risks relating to aml

ABSTRACT

Systems and methods for identifying and mitigating non-compliances include determining an agent location of a money service business for review, obtaining a photograph and geographic coordinates of the agent location, and collecting field data at the agent location through a mobile application. Such information are sent from the mobile application to a central server of a third party vendor for a series of quality checks and stored at the central server. Such information may be used for further corrective action against the agent location reviewed.

CROSS-REFERENCES TO RELATED APPLICATIONS

This application is a continuation of U.S. patent application Ser. No.14/964,290, filed Dec. 9, 2015, which claims priority to ProvisionalU.S. Patent Application No. 62/236,453, filed Oct. 2, 2015, the entiredisclosures of which are hereby incorporated by reference, for allpurposes, as if fully set forth herein.

BACKGROUND

Money service businesses (“MSBs”) may include persons or organizationsthat provide a variety of financial products and services, includingcurrency exchange; cashing checks; issuing, selling, and/or redeemingtraveler's checks, money orders, or stored value cards; and transmittingmoney. When providing these products and services, MSBs must operate incompliance with regulatory controls, including anti-money laundering(“AML”) rules, know-your-customer (“KYC”) rules, suspicious activity andcurrency reporting (“SAR”) rules, and/or various other identification,documentation, and record keeping rules, which may vary based onjurisdiction. To comply with these and other regulatory controls, MSBsoperate under programs and procedures that may be based on riskassessments of the company's vulnerabilities to AML, KYC, and/or SARnon-compliance issues. Such programs and procedures are intended toprevent improper use of the products and services offered at the MSBs,such as illegal or improper money transfers including money laundering,payment for illicit products or services, and funding of terrorist orother criminal activity.

Many MSBs operate and distribute their financial products and servicesthrough a system of agents or vendors, which may include local and/oroverseas counterparts that are also required to operate in compliancewith regulatory controls. Typically, such agents and vendors operateunder the supervision of a MSB or other entity, and utilize periodictraining of their employees in an effort to ensure that such regulatorymeasures are in practice. For example, compliance tests or evaluationsare conducted by officers physically visiting and checking agent andvendor locations. However, due to an ever-increasing number of agent andvendor locations, such approaches are hampered by variousinefficiencies, increasing costs, and resource constraints. Further,such approaches largely rely on staff at the agent location to supportthe supervisory initiative and therefore are prone to bias and/orcollusion. Finally, current trends toward increasing regulatoryexpectations require greater responsibility and control from the MSBs inconducting the compliance tests.

Issues affecting the traditional methods for conducting compliance testsmay include a failure to validate presence of the staff, such aspresence of the agents and officers, at their appropriate locations.Compliance data at the locations is often collected manually, whichrequires the staff to return to a base station and manually input theirfindings into a spreadsheet or other program at a central hub, oftenusing computing resources of that central hub. Further, currentcompliance tests include evaluations that are susceptible to humansubjectivity, including individual interpretation, bias, and/or errorswhich may skew an entire compliance report, particularly whererisk-assessment questions overlap amongst various functions of theagents/officers. Furthermore, current evaluations lack real-timesubmission capabilities and/or real-time review, thereby contributing todelayed analysis and subsequent delays in the calibration of employeetraining and auditing needs. Scaling up the frequency and volume ofreviews is also challenging because, in the existing infrastructure, itmay entail greatly increased costs and human resource requirements.

Therefore, there is a need for improved infrastructure that facilitatesthe oversight, development, updating, and enforcement of complianceprograms, particularly for financial institutions such as MSBs.Embodiments of the current invention may address these and other issues.

BRIEF SUMMARY

This invention generally relates to systems and methods for reducingrisks relating to financial products and services, and morespecifically, to systems and methods for identifying and mitigatingrisks related to AML and/or KYC non-compliances.

In one aspect, the present disclosure provides a method for reviewing anagent location of a money service business (“MSB”) in order to identifyand mitigate risks due to non-compliance. The agent locations thatrequire review may be identified by the MSB and passed on to a thirdparty vendor. The method may include determining, at a central server,the agent location for review by a field task force (“FTF”). The reviewmay be performed by a FTF of the third party vendor that is appointed bythe MSB for physically visiting the agent location to conduct thereview. The method may also include receiving, potentially in real-timeby the central server, details of the review from a mobile applicationon a mobile device, including possibly a digital photograph and/or aconfirmation of training received by the location staff. The digitalphotograph of the agent location (potentially with date and/or timestamp) may be captured by the mobile application during the review. Themethod may further include receiving, by the central server, geographiccoordinates from the mobile application. The geographic coordinates maycorrespond to a location where the digital photograph was captured fromduring the review. In another aspect, the method may include receiving,by the central server, field data from the mobile application during thereview. The field data may be obtained via a questionnaire provided bythe mobile application and the questionnaire may predictnon-compliances. During the visit, the FTF shall also train the agentlocation staff on the basic requirements of providing the service. In adifferent aspect, the method may include, upon receiving the field dataat the central server, automatically prompting, by the central server, aquality control (“QC”) consultant for input relating to a first qualitycheck. During a first quality check, while the FTF is still in thevicinity of the location being reviewed, the QC may contact the FTF forany clarifications related to the inputs received from the FTF andaccordingly update the review information. The first quality check mayensure consistency of the field data obtained during the review andidentify any training needed for the agent location and/or FTF. Thereview may be considered to be complete only after the QC consultantensures completeness of the review report. Upon receiving clearance fromthe QC consultant, the FTF may continue with his or her next review. Themethod may include, after performing the first quality check and/or postcompletion of the review, automatically prompting, at the centralserver, a chartered accountant for input relating to a second qualitycheck (i.e., scheduling such an accountant for the second quality checkand/or input). The second quality check may identify any training neededfor the FTF and/or the QC consultant. The method may include recording,at the central server, information from the review including the digitalphotograph, geographic coordinates, field data collected during thereview, input relating to the first quality check, and input relating tothe second quality check.

Various embodiments of the method may include one or more of thefollowing features. The central server may correspond to the third partyvendor, and the central server may be in operative communication with ahost system corresponding to the MSB. The method may includetransmitting, by the central server, the information from the review tothe host system corresponding to the MSB. The host system may analyzethe information from the review to determine a subsequent action itemfor the agent location. The central server may evaluate each response inthe questionnaire, and based on a scoring matrix provided by the MSB,assign a score. Subsequent action items may include implementing anemployee training protocol (also referred to as an employee escalationprotocol) such as suspension or training based on the final reviewscore. In these or other embodiments, subsequent action items may alsobe based on a response to any particular given question or questions.Additionally, in some embodiments, subsequent action items may also bebased on a combination of the final review score and a response to anyparticular given question or questions. The employee training protocolmay be selected by the MSB to address non-compliances predicted by thefield data obtained in the questionnaire. The method may includecommunicating, by the central server via a wireless network, with themobile application on the mobile device to receive the information fromthe review while the mobile device is located remotely from the locationof the central server. In another aspect, the method may includedetermining, at the central server, a plurality of agent locations forreview, simultaneously conducting, at the central server, a plurality ofreviews for the determined agent locations, and recording, at thecentral server, the plurality of reviews for the determined agentlocations.

Further embodiments of the method may be contemplated to include one ormore of the following features. The method may include determining, atthe central server, the agent location for review based on instructionsreceived from the MSB. The instructions may be based at least in part onrisk and quality check analyses of previous reviews for the agentlocation. The method may include generating, by the central server, ascore indicating a successful completion of the review based oncompletion of the first quality check. Successful completion may also bedependent on the answer to any particular given question or questions onthe questionnaire. The score or other factor indicating the successfulcompletion of the review may permits the FTF to proceed to review adifferent agent location. The method may include marking, by the centralserver, the review as closed based on the score or other factor. Inanother aspect, the method may include prompting, by the central server,the QC consultant for the input relating to the first quality check inreal-time upon receiving the digital photograph, geographic coordinates,and field data. The method may include, based on the input relating tothe first quality check, contacting, by the central server in real-timeupon receiving the field data, the FTF for at least one of furtherclarification regarding the field data obtained via the questionnaire,correcting the field data obtained via the questionnaire, and providingtraining to the FTF responsible for conducting the review.

Further, the features of the method may include contacting the FTF byplacing a call externally by a communication device or via atelecommunications network, to the mobile device of the FTF, whereby thecall may be initiated by an input from the QC consultant at the centralserver. The method may include receiving, by the central server via awireless communication network, a notification from the mobileapplication to escalate the review for the agent location. Thenotification to escalate the review may be based on a trigger identifiedby the mobile application. The method may include notifying a hostsystem of the MSB to escalate the review, whereby escalating the reviewmay prompt the MSB to determine subsequent actions to address theidentified trigger. The questionnaire may include dichotomous questionshaving two possible response options. The two possible response optionsmay include at least one of a yes/no response options, a true/falseresponse options, and an agree/disagree response options. Thequestionnaire may include a plurality of questions, and each of theplurality of questions may be auto-generated in real-time by the mobileapplication, potentially based on responses received for precedingquestions in the questionnaire.

Still further, each of the plurality of questions may be determinedbased on an objective risk matrix to predict and auto-load nextquestions in the questionnaire based on previous responses. Thequestionnaire may be stored at the mobile device having the mobileapplication such that the questionnaire is accessible with and withoutconnectivity to a wireless communications network. The method mayinclude assigning, by the central server, the review for a third qualitycheck. The third quality check, this time possibly by an alternateresource, may include physically verifying the identified locationindependently and feeding results to the central server and validating,by the central server, the inputs from the review with a precedingreview for the agent location to identify one or more inconsistencies.The method may include receiving, by the central server, feedbackdirected to a FTF training action from a host server of the MSB. Thefeedback may be based at least in part on the information from thereview. The method may include notifying, by the central server, themobile device of the FTF regarding the feedback directed to the FTFtraining action.

In another aspect of the present disclosure, a system for reviewing anagent location of a money service business (“MSB”) in order to identifyand mitigate risks due to non-compliances is provided. The system mayinclude a mobile device having a mobile application configured tocollect field data during a review of the agent location. The system mayfurther include one or more processors and a memory communicativelycoupled with and readable by the one or more processors. The memory mayhave stored therein processor-readable instructions that, when executedby the one or more processors, cause the one or more processors toperform one or more functions to review the agent location. Forinstance, the processor-readable instructions may cause the one or moreprocessors to determine, at a central server, the agent location forreview, whereby the review may be performed by a field task force(“FTF”) of a third party vendor that is appointed by the MSB forphysically visiting the agent location to conduct the review. Theprocessor-readable instructions may cause the one or more processors toreceive, by the central server, a digital photograph from a mobileapplication on a mobile device, whereby the digital photograph iscaptured by the mobile application at the agent location during thereview. The processor-readable instructions may cause the one or moreprocessors to receive, by the central server, geographic coordinatesfrom the mobile application, whereby the geographic coordinates maycorrespond to a location where the digital photograph was captured fromduring the review.

In a further aspect, the processor-readable instructions may cause theone or more processors to receive, by the central server, field datafrom the mobile application during the review, whereby the field datamay be obtained via a questionnaire provided by the mobile application,further where the questionnaire may predict non-compliances. Theprocessor-readable instructions may cause the one or more processors to,upon receiving the field data at the central server, automaticallyprompt, by the central server, a quality control (“QC”) consultant forinput relating to a first quality check. The first quality check mayensure consistency of the field data obtained during the review andidentify any training needed for the agent location. Theprocessor-readable instructions may cause the one or more processors to,after performing the first quality check, automatically schedule/prompt,at the central server, a chartered accountant for input relating to asecond quality check. The second quality check may identify any trainingneeded for at least one of the FTF and the QC consultant. Theprocessor-readable instructions may cause the one or more processors torecord, at the central server, information from the review including thedigital photograph, geographic coordinates, field data collected duringthe review, input relating to the first quality check, and inputrelating to the second quality check.

In yet another aspect of the present disclosure, a computer-readablemedium has stored thereon a series of instructions which, when executedby a processor, cause the processor to review an agent location of amoney service business (“MSB”) in order to identify and mitigatenon-compliances. The series of instructions may include determining, ata central server, the agent location for review. The review may beperformed by a field task force (“FTF”) of a third party vendor that isappointed by the MSB for physically visiting the agent location toconduct the review. The series of instructions may include receiving, bythe central server, a digital photograph from a mobile application on amobile device. The digital photograph may be captured by the mobileapplication at the agent location during the review. The series ofinstructions may include receiving, by the central server, geographiccoordinates from the mobile application. The geographic coordinates maycorrespond to a location where the digital photograph was captured fromduring the review.

Further, the series of instructions may include receiving, by thecentral server, field data from the mobile application during thereview. The field data may be obtained via a questionnaire provided bythe mobile application, whereby the questionnaire may predictnon-compliances. The series of instructions may include, upon receivingthe field data at the central server, automatically prompting, by thecentral server, a quality control (“QC”) consultant for input relatingto a first quality check. The first quality check may ensure consistencyof the field data obtained during the review and identify any trainingneeded for the agent location. The series of instructions may include,after performing the first quality check, automaticallyscheduling/prompting, at the central server, a chartered accountant forinput relating to a second quality check. A “chartered accountant,” asused herein, may include an actual chartered accountant in suchjurisdictions as they exist, or otherwise by a qualified representativeof the MSB, or other designated party. The second quality check mayidentify any training needed for at least one of the FTF and the QCconsultant. The series of instructions may include recording, at thecentral server, information from the review including the digitalphotograph, geographic coordinates, field data collected during thereview, input relating to the first quality check, and input relating tothe second quality check.

BRIEF DESCRIPTION OF THE DRAWINGS

FIG. 1 shows an example method for identifying and mitigating risksrelating to non-compliances;

FIG. 2 shows an example system for identifying and mitigating risksrelating to non-compliances;

FIG. 3 shows another example method for identifying and mitigating risksrelating to non-compliances;

FIG. 4 shows an example communications sequence for identifying andmitigating risks relating to non-compliances;

FIG. 5 shows an example computer architecture upon which various aspectsof the present invention may be implemented; and

FIG. 6 shows another example method for identifying and mitigating risksrelating to non-compliances.

It is noted that any of the elements and/or steps provided in the blockdiagrams, flow diagrams, method diagrams, and other illustrations of thefigures may be optional, replaced, and/or include additional components,such as combined and/or replaced with other elements and/or steps fromother figures and text provided herein. Various embodiments of thepresent invention are discussed below, and various combinations ormodifications thereof may be contemplated.

DETAILED DESCRIPTION

In the following description, for the purposes of explanation, numerousspecific details are set forth in order to provide a thoroughunderstanding of various embodiments of the present invention. It willbe apparent, however, to one skilled in the art that embodiments of thepresent invention may be practiced without some of these specificdetails. In other instances, well-known structures and devices are shownin block diagram form.

The ensuing description provides exemplary embodiments only, and is notintended to limit the scope, applicability, or configuration of thedisclosure. Rather, the ensuing description of the exemplary embodimentswill provide those skilled in the art with an enabling description forimplementing an exemplary embodiment. It should be understood thatvarious changes may be made in the function and arrangement of elementswithout departing from the spirit and scope of the invention as setforth in the appended claims.

Further, specific details are given in the following description toprovide a thorough understanding of the embodiments. However, it will beunderstood by one of ordinary skill in the art that the embodiments maybe practiced without these specific details. For example, circuits,systems, networks, processes, and other components may be shown ascomponents in block diagram form in order not to obscure the embodimentsin unnecessary detail. In other instances, well-known circuits,processes, algorithms, structures, and techniques may be shown withoutunnecessary detail in order to avoid obscuring the embodiments.

Also, it is noted that individual embodiments may be described as aprocess which is depicted as a flowchart, a flow diagram, a data flowdiagram, a structure diagram, or a block diagram. Although a flowchartmay describe the operations as a sequential process, many of theoperations can be performed in parallel or concurrently. In addition,the order of the operations may be re-arranged. A process is terminatedwhen its operations are completed, but could have additional steps notincluded in a figure. A process may correspond to a method, a function,a procedure, a subroutine, a subprogram, etc. When a process correspondsto a function, its termination can correspond to a return of thefunction to the calling function or the main function.

The term “machine-readable medium” includes, but is not limited to,portable or fixed storage devices, optical storage devices, wirelesschannels and various other mediums capable of storing, containing orcarrying instruction(s) and/or data. A code segment ormachine-executable instructions may represent a procedure, a function, asubprogram, a program, a routine, a subroutine, a module, a softwarepackage, a class, or any combination of instructions, data structures,or program statements. A code segment may be coupled to another codesegment or a hardware circuit by passing and/or receiving information,data, arguments, parameters, or memory contents. Information, arguments,parameters, data, etc. may be passed, forwarded, or transmitted via anysuitable means including memory sharing, message passing, token passing,network transmission, etc.

Furthermore, embodiments may be implemented by hardware, software,firmware, middleware, microcode, hardware description languages, or anycombination thereof. When implemented in software, firmware, middlewareor microcode, the program code or code segments to perform the necessarytasks may be stored in a machine readable medium. A processor(s) mayperform the necessary tasks.

In general, the systems and methods described herein provide foridentification and mitigation of risks that are related tonon-compliance of AML, KYC, and other regulatory and/or operationalcontrols. In some examples discussed herein, the systems and methodsemploy a mobile application, such as an Android™ or iOS™ mobileapplication, which may include or otherwise utilize an objectivequestionnaire, a risk scoring matrix, and/or a case escalation matrix.In some embodiments, some or all logic/functionality may be performed ata remote server such as those discussed herein. It is contemplated thatthe systems and methods described herein may provide for a real-timeevaluation process that is objective and allows for subsequentremediation and/or exclusion measures, if any, to be promptlyimplemented at an agent location being investigated. In practice, thesystems and methods may be implemented to conduct compliance evaluationsfor a multitude of third party agents and/or representatives that form aservice network of a money service business (“MSB”). Merely by way ofexample, a MSB such as WESTERN UNION, may use the systems and methodspresented herein to perform evaluations and implement certain actionsbased on the evaluations, individually and/or collectively,simultaneously and/or sequentially, across a plurality of agentlocations. In some cases, the agent locations may be highly dispersedacross a large geographical area, such as, merely by way of example, thethousands of agent locations that provide WESTERN UNION operations thatare distributed throughout India. Through implementation of the systemsand methods described herein, the MSB may effectively and objectivelyensure that its internal operations comply with both jurisdiction-basedrules, such as India or other jurisdiction specific standards,world-wide governing controls, such as the AML/KYC rules, and/or meetoperational guidelines such as Western Union expected standards andguidelines.

As an example implementation, a MSB, such as Western Union FinancialServices Inc. (“WUFSI”) may be authorized to provide money transferservices for inbound and outbound cross border money transactions, suchas transmitting money from customer to customer globally. Suchauthorizations may be given to the MSB by local institutions in anycountry or jurisdiction where the MSB intends to operate. Merely by wayof example, WUFSI operating in India may be authorized by The ReserveBank of India (“RBI”) under various laws, such as The Payments andSettlements Systems Act, 2007 (“PSA”), among other certifications, toprovide money transfer services and may be subject to various terms andconditions detailed by the RBI approval. Consequently, in this example,with the RBI approval, WUFSI in India may be regarded as the “OverseasPrincipal” under a money transfer service scheme (“MTSS”) and also as a“Payment System Operator” under the PSA.

In some examples, the MSB may have a plurality of third parties thatdistribute the financial goods and services provided by the MSB. Merelyway by of example, WUFSI operations in India may include a servicenetwork that comprises one or more MTSS representatives throughoutIndia. In such a specific implementation, WUFSI operations in Indiacurrently utilize nine MTSS representatives, including India Post, StateBank of India, Andhra Bank, Karnataka Bank, Paul Merchants Limited,YourFirst Money Express Private Limited, Transcorp InternationalLimited, Weizmann Forex Limited, and Wall Street Finance Limited. Suchrepresentatives may offer WUFSI-branded financial products and servicesthrough their own locations and/or sub-representative locations (in thisexample, throughout India). Such locations and/or sub-representativelocations may include agent locations, kiosks, webpage and/or softwareapplications, and other tools and mechanisms.

In the above example, while operating in India, WUFSI is required toadhere to terms and conditions detailed in the RBI authorization, andmore specifically in the Certificate of Authorization portion stipulatedby the RBI. Under the Certificate of Authorization, WUFSI is responsibleand accountable for the activities of its network of agents, sub-agents,representatives, and sub-representatives distributed throughout India.Accordingly, WUFSI runs a highly regulated business that includesregularly training its network on the intricate rules of the regulatorycontrols and regularly auditing the network to ensure that the rules arebeing followed. Therefore, close and continuous oversight of the agentsand representatives is a requirement for WUFSI acting as the OverseasPrincipal, whereby WUFSI is responsible for the activities of the agentsand sub-agents in India. It is noted that although WUFSI in Indiaoperations are exemplified, any MSB operating in any country mayencounter similar requirements and responsibilities and/or wish to putin place similar controls.

Such networks of MSBs may include hundreds of thousands of agents andrepresentatives that are highly distributed and continuously beingestablished throughout a geographical area. For example, WUFSI may haveover 105,000 locations in its ever-growing network throughout India.Given the large number of locations and mixed class of trade in thenetwork, a MSB such as WUFSI may appoint a third party vendor tofacilitate conducting reviews on the agent locations. In other examples,the MSB may conduct such reviews on their own. With the present systemsand methods discussed herein, the MSB such as WUFSI may implement thethird party review process with a set risk questionnaire that isprovided, approved, and/or otherwise determined by the MSB. In someembodiments, the level of quality control employed by the third partymay be determined by the MSB or any other party discussed herein.Further, with the systems and methods discussed herein, the MSB mayimplement a scoring mechanism that is used for evaluating a risk levelof the reviewed agent location based on the questionnaire feedback, sothat appropriate consequent actions, if any, may be taken, eitherimmediately (near real-time) or at pre-designated time periods.Furthermore, through the systems and methods discussed herein, asufficient trail may be created for regulatory bodies, such as the RBIand/or other law enforcement agencies. Such trails may provide evidencedemonstrating that: 1) a correct location was visited during the review;2) consistent and objective approach to the regulatory program wasimplemented; 3) appropriate action(s) per the defined scoring matrix andescalation policy(s) were implemented; 4) strong quality checkprocedures were applied; 5) the MSB's compliance with regulatoryexpectations have been met.

It is noted that in some examples, location review procedures disclosedherein may require staff of the third party vendor to travel to a largenumber of agent locations to conduct the reviews. In the above example,the third party vendor may send the staff, also referred to herein asthe “field task force,” to remote locations throughout India where theagents and sub-agents are located, e.g. spread over a large geographicalarea of approximately 3,287,240 sq. km. In that case, physicalverification by the MSB, such as by employees of the MSB, of the agenttraining, reviews, and/or any actions performed by the MSB-appointedfield task force may be prohibitive. For example, with previous methods,whereby MSB in-house staff would physically visit the agent locations,only about 1% to 3% of the agent locations could be covered due to theincreased location numbers, cost and resource constraints. In anotheraspect, collusion between the agent or sub-agent and field task forcemay lend to inflated achievements of set targets. In summary, it iscontemplated that the present systems and methods disclosed herein mayprovide benefits that address such issues and provide relatedadvantages.

For example, the present systems and methods disclosed herein may verifythat the staff of the third party vendor is physically present at theagent location being reviewed, and that such staff is impartingnecessary training for employees and collecting adequate data for theMSB to ascertain the risk level and/or other required actions and tasks.The present systems and methods may provide the feedback and quality oftraining to the MSB in real-time, which may mitigate tampering thatmight arise from collusion between the third party vendor and the agentor sub-agent, e.g. inflating achievement of targets. The systems andmethods disclosed herein may further minimize subjective human bias anderror from the agents, sub-agents, and/or the field task force byutilizing an objective questionnaire, which may lead to a more accurateprediction of risk. The procedures may also allow for confirmation ofphysical presence of a location and provide comfort that there are no“ghost” locations processing transactions.

Additionally and/or alternatively, the systems and methods disclosedherein may employ a plurality of unique quality checks to validate theagent location review process. Further, it is worthy to note that insome examples of the systems and methods disclosed herein, the onsitereviews conducted by the staff of the third party may be furthervalidated by a separate and independent personnel making anotherphysical visit and conducting real-time determination that the fieldvisit has been properly completed. In further examples, real-timeevaluation of the reviews conducted by the third party vendor may allowthe MSB to respond to suspicious or improper activities in real-time bysuspending or terminating operations, thereby preventing potentialoffences and/or contravention. In another aspect, real-time calibrationof any weak locations or operations within the network allows the MSB totrack and more efficiently deploy training and/or auditing resources.

Apart from adhering to local compliance requirements, the presentsystems and methods disclosed herein may allow the MSB to bettermitigate the risk of their products and services being used for unlawfulpurposes, such as money laundering, fraud, and terrorist financing, andalso reduce instances of fines or penalties as a result of their networknot following procedures correctly. Not only do such measures protectthe MSB, but further, contribute to the protection of the globalfinancial system against potential abuses. In another example, thesystems and methods disclosed herein may be implemented globally as aglobal agent oversight program through similar solutions or in-housesolutions. Other benefits and implementations are possible.

According to some aspects of the present disclosure, the staff of thethird party vendor uses a wireless application protocol (“WAP”) enabledwireless communication device to collect information, such as a generalpacket radio service (“GPRS”) device, e.g. an Android-based tablet orcell phone. Information may be collected from the staff via aquestionnaire format that is created or tailored by a main user orapplicant conducting the review, such as the MSB. The data may becollected through a mobile application that is specifically developedfor the purpose of conducting reviews in complying with regulatorycontrols and/or internal requirements. The questionnaire may either beimplemented completely or be based on a predictive risk methodologywhereby a series of questions are generated and/or predicted inreal-time. In some examples, the questionnaire selects subsequentquestions in real-time based on answers received in preceding questionsof the questionnaire during a same session or from a different reviewsession. The real-time nature of such predictive aspects of thequestionnaire and response feed may enable the systems and methodsdisclosed herein to better assess the scope and extent of any risksidentified.

It is contemplated that the mobile application, the review of sampledocuments, and/or the responses to questions, allow for properassessment by the MSB of the agent location. The objective responses fedinto the mobile device may be utilized by the MSB to determineappropriate next actions based on a risk-matrix, which aids the MSB indeciding whether further probe and/or review of the agent location isrequired. With the systems and methods disclosed herein, such actionsmay be determined with little to no impact from any subjectiveinterpretation of the respondents and/or the third party vendorconducting the audit by way of objective questionnaire. Further,responses to the individual questions in the questionnaire may beutilized to create and provide focused training to the employees at theagent location to address any particular deficiencies identified in thereview process. Such focused training may be provided by the MSB, by thestaff of the third party vendor reviewing the agent location, and/orbased on the risk determined, by the staff of the agent who has beenarranged to provide the MSB service at a location and/or in some cases,based on the risk determined, by the employees of the MSB.

In another aspect, data or information collected via the questionnairemay pass through a scoring matrix, which may be developed and/orotherwise tailored in-house by the applicant, such as the MSB. Thescoring matrix may provide a real-time computation of the deficiencies,attendant risk, and/or remedial actions needed. Subsequent appropriateaction(s) may be triggered automatically by the systems and methodsdisclosed herein. In some examples, subsequent actions may includegenerating, by the systems and methods disclosed herein, emails based onthe questionnaire results and/or scoring matrix to notify stakeholders.Such emails and other actions may be performed by a central system, suchas server of the third party vendor or a host system of the MSB,potentially whichever receives and hosts all information relevant forthe agent location reviews and notifications. Additional and/oralternative actions may be required by the central server and/or hostsystem to target and mitigate any risks of AML/KYC non-compliances,and/or possible or potential threats to maintaining compliance thereof.

In a further aspect, the systems and methods disclosed herein comprisebuilt-in controls that allow for geo-tagging of an agent location beingreviewed. In this way, information and evidence of where the review wasconducted may be recorded. In some examples, such information isautomatically embedded by the mobile application in the data that iscollected by the third party vendor's staff via the questionnaire and iscommunicated in real-time or in an offline mode to the third partyvendor and/or MSB's server or host system. In another example, suchlocation data may also be embedded by the mobile application to aphotograph taken via the mobile application of the location beingreviewed. The mobile application may upload or otherwise communicate thegeo-tagged coordinates and/or captured photograph to the host systemand/or vendor's server. In some aspects, the mobile application may addthe location, date, and time stamp of the photograph, in addition toscanning all or a portion of the questionnaire, such as a page of thequestionnaire where the third party vendor's staff signs off on thereview. The field staff may not be able to externally or otherwisecapture the geo-coordinates or photograph and communicate to the centralserver or the host server. It is contemplated that such measures may betaken to confirm the presence of the third party vendor's staff at thecorrect agent location. The geo-tagged co-ordinates may be used forvalidating subsequent review of the same location.

In some examples, any data that is collected by the third party vendor'sstaff via the mobile application may be streamed online to a vendorserver and/or MSB host system. In one example, the information isstreamed to the vendor's server, where a quality control (“QC”)consultant reviews such information as it is collected by the field taskforce, immediately after it is collected by the field task force, and/orotherwise. If any inconsistencies are discovered by the QC consultant,the QC consultant may contact, in real-time, the third party vendor'sstaff for additional information. For instance, the QC consultant maycontact the third party vendor's staff via the mobile application and/ormobile device. Where necessary, responses to the questionnaire and/orany portion of the risk assessment may be corrected by the QC consultantbased on his or her interactions with the third party vendor's staff. Anaudit log may be maintained by the mobile application, server and/orhost system for any such changes. In some aspects, once the QCconsultant approves the information collected by the third party vendorstaff, the information is stored in the server and/or host system andthe review may be marked as completed and/or scored. Furthermore, thissetup may be used to provide regular training to the FTF and thus ensureeffectiveness of the review. Such training could be through streaming oftips related to specific topics of the review or testing the knowledgeof the FTF by asking a direct question or a combination of directquestions related to the review activity. Where such tests areconducted, the FTF may be required to answer each and all of thequestions for which input is required and may be allowed to continue thereview once all questions are correctly answered or after a follow-uptraining by the third party team (which may be conducted by the QCconsultant, a training manager, a supervisor, and/or any other personwithin the third party team).

It is worthy to note that the present systems and methods may utilizeany of a variety of quality controls to help confirm that theinformation received is complete and/or accurate. In the event that theequipment, such as the mobile device and/or application, is not working,the review may be marked as an exception case. In that case, the thirdparty vendor's staff may manually collect the information based on abackup/physical questionnaire that is designated for such exceptioncases, and/or forward results of the questionnaire to the vendor'sserver at a later time, either through mail or through a WEB applicationthat allows capture of the information relevant to the questionnaire. Inanother aspect, if the mobile device and/or application is working, butthere is no network or telecom connectivity, data and/or responses tothe questionnaire may be collected in an offline mode. Additionallyand/or alternatively, data may be manually collected. Any such data maythen be transmitted automatically by the mobile device and/orapplication when connectivity is determined by the device to beavailable. In an aspect, the questionnaire, and/or the backupquestionnaire, may be accessed by the mobile device and/or theapplication regardless of network connectivity status, e.g. thequestionnaire may be built-in to the mobile application and/or stored onthe mobile device itself.

Upon receiving such uploaded information, the quality check process maybe initiated by the QC consultant. In some situations, the QC proceduremay require the third party vendor's staff to return to the agentlocation to collect additional information for evaluation. In some caseswhere the QC consultant determines that the agent location has to bere-reviewed, the original review may be canceled on the system and/orreplaced with a new review. Such changes may be recorded in an auditlog. In another aspect, a supervisor or another independent staff of thethird party vendor's staff may conduct a 10% quality check, whereby 10%of all of the reviews and responses are systemically verified with theprevious or original reviews for the particular agent location toidentify any inconsistencies. In yet another aspect, a charteredaccountant may conduct a quality check of every review for consistencyand may help identify any training needed for the third party vendor'sstaff and/or the QC consultant. In cases where a physical form may beutilized by the third party vendor's staff for collecting data on theagent location, such physical forms may be scanned and uploaded in theMSB's host system. In yet another aspect, the electronic questionnaireand responses, along with the photograph(s) taken at the agent location,geo-tagging information, and/or quality check updates may be directlyformatted, by the systems and methods disclosed herein, to a PDF and/orHTML file. Such files may be uploaded and/or otherwise stored at theMSB's host system. Other formatting and examples are possible.

In general, the present systems and methods disclosed herein providevarious benefits for the MSB, including the capability to validate thepresence of the vendor's third party staff at the correct agentlocation. Quality control of the reviews is enhanced with real-timetechnology and communications between the vendor's third party staff,the QC consultant, and/or the MSB host system. Evaluation of the agentlocation is based on an objective matrix that ensures consistency inevaluations across a multitude of agent locations, as well as for thesame agent location being re-evaluated. The objective risk matrix maywork in concert with the predictive risk questionnaire to possibly autoload next questions based on previous responses. Real-time feed of theobjective results allows for calibration of training and audit needs,thereby reducing risks and allowing weak spots to be identified andfocused upon for improvement. Scaling up the number of objective,quality reviews of agent locations is possible. In an aspect, thesystems and methods described herein may allow for an increasedfrequency of reviews of agent locations to be conducted and qualitychecked than before. On-spot remediation, suspension, and/or terminationof agent locations based on the review of the third party vendor's staffand/or subsequent quality check(s) is possible. Collection of sampletransaction information and/or physical evidence through thequestionnaire may be used to validate whether the third party vendor'sstaff visited the correct location, and/or to confirm an address of theagent location as listed in the MSB's records. The MSBs may initiatetheir own sample checks periodically that may be used to validate theefficacy of the program/review process, to obtain feedback tocorrect/enhance the program/process or to provide feedback/training tothe third party vendor management/staff.

As described above and further in the succeeding paragraphs, the presentsystems and methods disclosed herein may aid MSBs in supervisingcompliance of their network of agents and representatives with AML/KYCpolicies and procedures. In some aspects, the systems and methodsdiscussed herein may aid the MSBs in keeping up-to-date with any changesor updates with the laws and regulations, business operation changes,and/or new risks identified, and to implement actions that addressand/or result from such changes throughout their network(s) in a moretimely and efficient manner. In another aspect, the AML/KYC programs setby the MSB may be updated to match changing business methods of the MSBand implemented with immediacy using the systems and methods discussedherein. Further, identification of non-compliances by the review processdiscussed herein may permit the MSB to apply any disciplinary actionswhen employee non-compliance is detected. In another aspect, the systemsand methods discussed herein may help ensure periodic retraining of theagent locations and/or the field task force, in part by way of thereal-time evaluations and quality checks discussed herein. Further,records of employee attendance and training may be logged by the systemsand methods discussed herein, such as the MSB host system, and/orreferenced in the questionnaire and risk evaluations. Generally, it iscontemplated that the present system and methods disclosed hereinensures that the AML/KYC program is implemented and operating and thatproblems are addressed immediately. Any non-compliance, such asdetecting and deterring improper uses of the products and servicesoffered by the MSB, may be identified, flagged, and/or thwartedimmediately in real-time through training or through MSB initiatedactions post-review.

Turning now to FIG. 1, an example method 100 for identifying andmitigating risks relating to AML/KYC non-compliances is shown. Themethod 100 may be performed by the third party vendor system, such as acentral server thereof. In other aspects, the method 100 may beperformed by a mobile application, which may be herein referred to as acompliance review mobile application that is provided on a mobile deviceutilized by the FTF of the third party vendor system. In yet anotherexample, the method 100 is performed by the MSB's host system. In stillanother example, the method 100 may be performed by a combination of thethird party vendor system's central server, the compliance review mobileapplication, and/or the MSB's host system. The method 100 may aid theMSB in meeting supervisory requirements and promote the oversight,development, update, and enforcement of such AML/KYC programs throughoutthe MSB's network. In one example, the method 100 is performed by acentral server of a third party vendor system, whereby the centralserver is in wireless communication with the mobile device that iscarried out to an agent location by the FTF for conducting the review.It is noted that any of the methods described herein may includeadditional steps and that any of the steps shown may be optional.

As shown in FIG. 1, the method 100 may include initiating a review ofthe agent location (step 102). In some examples, initiating the reviewmay include determining the agent location to be reviewed. The agentlocation may be determined by the MSB host system, which utilizes avolume-risk based matrix or any other risk triggers to identifylocations that should be reviewed. Such information and/or determinedagent locations may be passed from the host system to the third partyvendor's central server. It is noted that the third party vendor, alsoknown as the external vendor, is appointed by the MSB for physicallyvisiting the agent location, conducting the review and providing basictraining. It is also noted that in some cases, reviews of agentlocations may be conducted without indication or prior notification tothe agent locations. In another aspect, the MSB and/or the third partyvendor may determine a routing for conducting a sequence of reviews at aplurality of agent locations that should be covered. For example, thethird party vendor may receive indication of which agent locations toreview from the MSB, assign one or more of the determined agentlocations to a FTF staff or team, and determine a best route forconducting the sequence of reviews. Such best routes may be determinedbased on a ranking of urgency for the review in comparison to reviews ofother agent locations, a fastest travel route, a most cost-effectivetravel route, and/or a combination of such factors, among others.

In one example, the central server of the third party vendor determinesthe agent location for review based on the information received from theMSB's host system. For instance, the central server may determine theagent location for review based on instructions received from the MSB,whereby the instructions are based at least in part on a risk andquality check analyses of previous reviews for the agent location. In afurther aspect, the central server may determine a plurality of agentlocations for review. The plurality of agent locations may be identifiedby the MSB and/or reviewed simultaneously, such that the third partyvendor performs multiple reviews using multiple FTF. It is contemplatedthat central server and/or the host system may be sufficient to handlelarge volumes of reviews being conducted, and to record such pluralityof reviews for the determined locations as documentation.

Referring again to FIG. 1, the method 100 may include receivingfield-visit data collected at the agent location by the FTF (step 104).Such field-visit data may be collected via the mobile application on themobile device and transmitted to the central server, and/or to the hostsystem, via a wireless network. It is contemplated that the mobiledevice may be located remotely from a location of the central serverand/or the host system, e.g. at the agent location. Such field data mayinclude a variety of data collected by the FTF and/or required by themobile application, such as responses to an objective questionnaire ofthe mobile application, one or more digital photographs corresponding tothe agent location, and/or one or more sets of geographic coordinatescorresponding to the agent location.

For example, the central server may receive the field data that isobtained via the questionnaire provided by the mobile application. Insome aspects, the questionnaire evaluates (and potentially predicts)non-compliance of the agent location and/or risks thereof. In somecases, the FTF may indicate that a location in the MSBs records mayactually not be performing the service, is closed temporarily orpermanently, and/or is otherwise unable to proceed with the audit. Insuch cases the mobile application may not prompt the full questionnaireand may only prompt for other validations such as obtaining aphotograph, geo-coordinates, etc. allowing the MSB, if necessary to takesuitable action. In one example, the questionnaire comprises dichotomousquestions that each has two possible response options for selection bythe FTF. Such response options per question may include a yes or noresponse option, a true or false response option, an agree or disagreeresponse option, and/or an answer A or answer B response option, amongothers. Some questions may have an additional option that indicateswhether the said question is applicable for the review/location. Thequestionnaire may comprise a variety of such response options. Inanother aspect, each of the plurality of questions may be auto-generatedin real-time by the mobile application as the FTF is inputting responsesto the questionnaire. For instance, the mobile application may determinea next question for the questionnaire based on one or more responsesreceived for one or more preceding questions in the questionnaire. Inother embodiments, all available questions may be asked. In someembodiments, each of the plurality of questions may be determined basedon an objective risk matrix that is utilized to estimate risks and toauto-load next questions in the questionnaire based on previousresponses. In some aspects, it is contemplated that the questionnaire isstored at the mobile device having the mobile application such that itis accessible with and without connectivity to a wireless communicationsnetwork. For instance, if no wireless connectivity is available duringthe review, the questionnaire may be configured to receive and store thequestionnaire responses until wireless connectivity is detected,whereupon the responses may be sent to the central server and/or thehost system.

It is contemplated that the questionnaire is configured to identifyand/or further provide information on whether an agent location's staffis trained on requirements for processing a money transfer transaction.Such requirements may include procedural steps that are implemented bythe MSB to ensure that its agent location staff operates in compliancewith rules and regulations. For instance, the questionnaire may identifywhether the agent location's staff is aware of what needs to be done forcertain scenarios, whether transactions below an X amount may be paid incash, which documentation from a client is allowable as verification fora product and/or service, and so on, to check if the staff is followingthe MSB's compliance programs and procedures. In one example, the MSBhost system may receive the completed questionnaire and review specificquestions to determine if any further review is required. For example,if an answer to a question is marked as “no”, however the MSB expectsthe answer to be “yes”, the MSB may perform an analysis to review theagent location further regarding issues related to that specificquestion. In another aspect, the MSB may review a plurality of agentlocation(s) that are identified as having answered “no” for a commonspecific question in their reviews. It is contemplated that such furtherprobing may be automated by the host system and/or be conducted byin-house staff at the MSB.

Further, it is contemplated that the questionnaire is objective andpredictive. More specifically, the questionnaire is configured topredict risk based on how questions are being answered. By offeringdichotomous questions, such as only answering yes or no, human errorand/or subjectivity may be reduced and/or mitigated. Further, efficiencyof the review may be increased while still collecting reliable data. Insome examples, a scoring methodology is utilized in the questionnaire bythe mobile application to predict and/or categorize risks. For instance,based on the responses received in the questionnaire, the mobileapplication may categorize the review and/or the agent location as a KYCbucket risk, an AML bucket risk, a transaction monitoring bucket risk,and/or other types of risks desired to be identified by the MSB. Suchcategorizations, along with any of the other types of field datacollected during the review, may be communicated with the MSB's hostserver and/or with the central server and utilized to determinesubsequent actions in real-time for the agent location. Merely by way ofexample, the MSB may determine, based on the risk identification and/orcategorization, to instantaneously, or in a pre-determined schedule,shut down the agent location, temporarily or permanently, if the risklevel exceeds a maximum acceptable level. In another example, the MSBand/or the third party vendor's central server or support staff thereofmay initiate training measures in real-time at the agent location toremediate any issues. In these ways, it is contemplated that the fielddata collected via the questionnaire may trigger follow-up measures fromthe MSB and/or the third party vendor in real-time, e.g. upon receivingand/or shortly after receiving the field data from the mobileapplication while the FTF is still at the agent location and availableto help implement such follow-up measures. Other examples are possible.

In another example, the field-visit data may include a digitalphotograph of the agent location being reviewed, whereby the digitalphotograph is taken at the agent location via the mobile application bythe FTF during the review. The digital photograph may be wirelesslytransmitted to the central server of the third party vendor and/or tothe MSB host system. In some examples, the digital photograph iswireless transmitted by the mobile application upon completion of thereview. In another aspect, the digital photograph is captured via themobile application upon completion of the questionnaire. A plurality ofphotographs may be taken of the agent location, such as uponcommencement of the review, in the middle of the review, and at an endof the review, which may include completing the questionnaire. In someaspects, the digital photograph may be automatically captured and/orprompted for capture by the third party vendor via the central system.For example, the central system may wirelessly signal the mobileapplication to cause the mobile application to automatically capture aphotograph and/or transmit the photograph to the central server forrecording and/or subsequent analysis. It is contemplated that thedigital photographs may be utilized to confirm visits made by the FTF,i.e. the FTF is physically on-site and at a correct agent location. Thedigital photograph may be transmitted along with the review information,such as the questionnaire responses, to the central server and/or thehost system.

In another aspect, a date and time stamp may be recorded on the digitalphotograph. In some examples, while any photo may be taken by a cameraon the mobile device and/or the tablet utilized by the FTF for review,such photos may be prohibited from being merged with the mobileapplication or uploaded to the central server and/or host system. Inother words, such photos that are not taken via the mobile applicationmay be prevented, by the mobile application, from being associated forthe review by preventing them from being uploaded and/or streamed onlineto the central server and/or the host system. This may prevent misuse ofthe mobile application, e.g. prevent the FTF from uploading a phototaken from a previous trip to the agent location as evidence of thecurrent visit to the agent location. In still other examples, the FTFmay conduct the review with physical forms, which the mobile applicationmay capture via the camera and/or otherwise scan and stream to thecentral server and/or host system. In still another aspect, a staffmember of the agent location may confirm that he or she is receivingtraining from the FTF by attaching his or her picture, which may also becaptured by the mobile application, to the data questionnaire. In thisway, further verification of the FTF's attendance at the correctlocation and performance of appropriate training tasks may be provided.Other examples are possible. For instance, the mobile application mayreceive confirmation of the training performed and/or agent locationbeing evaluated by receiving a seal that may be affixed by a staff, suchas an agent at the agent location, and/or by the FTF, to thequestionnaire and/or the digital photograph. This may provideconfirmation that the FTF visited the correct agent location and/or thatproper training was provided for the correct agent.

In yet another example, the field-visit data may include geographiccoordinates captured by the mobile application through a globalpositioning system (“GPS”) tracker on the mobile device. For instance,the coordinates may correspond to a location where the digitalphotograph is captured from during the review. In that case, it iscontemplated that the location is in close proximity and/or at a set ofgeographic coordinates corresponding to the agent location beingreviewed. The captured geographic coordinates may be transmitted fromthe mobile application to the central server and/or host system forverification of the FTF's location. In an aspect, the mobile applicationmay geo-tag any digital photograph taken via the mobile application tomark an attendance of the FTF being online and/or being at the correctlocation. In another aspect, the mobile application may capture a set ofgeographic coordinates in periodic intervals to track the FTF movementsand/or route. In yet another aspect, the mobile application may capturethe geographic coordinates upon receiving a prompt from the centralserver and/or the host system. In that case, the mobile application mayautomatically capture and transmit the geographic coordinates withoutany input from the FTF. The geographic coordinates may further be usedfor validation for subsequent visits of the FTF. For instance, aprevious set of geographic coordinates may be compared, by the mobileapplication, the central server, and/or the host system, with a currentset geographic coordinate corresponding to a currently active review toensure that the FTF is at the correct location. These geo-coordinatesmay have other uses such as pin-pointing on a map a location providingthe MSB service to a potential customer, to another reviewer of thethird party, and/or to a staff of the MSB.

As shown in FIG. 1, the method 100 may include performing a firstquality check in real-time (step 106). For instance, upon receiving thefield data at the central server, the method 100 may includeautomatically prompting, by the central server, a quality control (“QC”)consultant for input relating to a first quality check. The firstquality check may be configured to ensure consistency of the field dataobtained during the review and/or identify any training needed for theagent location based on the field data collected. The central server mayprompt the QC consultant for input relating to the first quality checkin real-time, that is, upon receiving the digital photograph, thegeographic coordinates, and/or the field data from the mobileapplication. In another example, the host system may perform the firstquality check. It is noted that a real-time first quality check mayprovide the third party vendor with an opportunity to train the FTFwhile the FTF is on-site at the agent location, and/or to train thestaff at the agent location with immediacy. In some cases, all or aportion of the first quality check may be automated. For instance, thecentral server may automatically identify issues related to thecollected field data and suggest various training programs to beimparted and/or further clarification that may be required. Suchsuggestions may be communicated to the QC consultant, such as via adisplay screen in operative communication with the central server. Inthat case, the QC consultant may perform subsequent actions, such ascontacting the FTF in real-time.

As further shown in FIG. 1, the method 100 may include contacting theFTF with action item(s), if any, regarding the received field-visit dataand the first quality check, among other possible quality checksdescribed further below (step 108). For example, based on the inputrelating to the first quality check, the method 100 may includecontacting, by the central server in real-time upon receiving the fielddata and/or conducting the first quality check, the FTF via the mobiledevice, and/or more specifically the mobile application, of the FTF.Merely by way of example, QC consultant and/or the central server mayseek for input from the FTF for at least one of further clarificationregarding the field data obtained via the questionnaire, correcting thefield data obtained via the questionnaire, and/or providing training tothe FTF responsible for conducting the review. Contacting the FTF mayinclude placing a call, from the central server or externally by acommunication device, via a telecommunications network, to the mobiledevice of the FTF, whereby the call may be initiated by an input fromthe QC consultant at the central server. In another aspect, the fielddata questionnaire and/or other portions of the review may be alteredand/or otherwise changed by input to the central server from the QCconsultant without contacting the FTF.

In still other examples, the method 100 may include receiving, by thecentral server via a wireless communication network, a notification fromthe mobile application to escalate the review for the agent location.The notification to escalate the review may be based on a triggeridentified by the mobile application, such as an unavailable agentlocation for review, an incomplete review, and/or other issues which maybe defined originally by the MSB as worthy of escalation. In that case,the method 100 may include notifying, by the central server, and/or thehost system of the MSB to escalate the review, whereby escalating thereview may prompt the MSB to determine any subsequent actions to addressthe identified trigger. Such actions may include establishing directcontact between the MSB and the agent location, suspending an activityof the agent location, closing the agent location, establishing contactbetween the MSB and the third party vendor, and/or identifying trainingrequired for the third party vendor and/or FTF. Other examples arepossible.

Still referring to FIG. 1, the method 100 may include performing asecond quality check. The second quality check may be performed by achartered accountant (step 110). It is noted that in some examples, thisstep may be optional. It is further noted that any of the steps providedherein may be optional, replaced, and/or rearranged, and that the method100 may include further steps not explicitly shown in FIG. 1. Merely byway of example, after performing the first quality check, the method 100may include automatically scheduling/prompting, at the central server,or as an external and separate process, a chartered accountant for inputrelating to a second quality check. The second quality check may beconfigured to identify any training needed for at least one of the FTFand the QC consultant. In another aspect, the second quality check mayreview the field data for inconsistencies in a same, similar, ordifferent approach as the first quality check. In yet another example,the second quality check may further be configured to identify anytraining that may be required for an agent at the agent location. Thechartered accountant may view an electronic form that is recorded onlineon the central server and/or the host system, or alternatively view aphysical questionnaire, whereby the form may be utilized to identify andrecord any issues identified by the accountant and/or store furtherinput from the chartered accountant. It is contemplated that such formsmay be subsequently provided to the MSB's host system for furtherevaluation.

In another aspect, FIG. 1 shows that the method 100 may includeassigning and/or performing a third quality check (step 112) for thereview. The third quality check may include a comparison of the reviewconducted, and/or more specifically the field-visit data collected, to aprevious review that was conducted by the same FTF and/or by a differentFTF. In some aspects, the third quality check may be automated by thecentral server and/or by the MSB host system. Such comparisons may aidin the identification of any inconsistencies between reviews and/orvalidate the currently captured field-visit data. In some aspects,comparing the field-visit data to previously collected field-visit datamay not only uncover inconsistencies, but also be utilized for analyzingimprovements and/or effects of any changes implemented at the agentlocation since the last review. In one example, the central serverand/or the host system periodically assigns a percentage of incomingreviews for a third quality check. Merely by way of example,approximately 10% of review cases every month may be reviewed bysupervisors or other independent FTF at the third party vendor and/orthe MSB, whereby the supervisors or other independent FTF review thedata collected by the FTF and/or in other quality checks, which arestored at the central server and/or host system. The supervisors mayanalyze results of the quality checks and/or field visit data bymatching them to previous quality checks and/or field visit data inorder to identify any deficiencies and/or changes in the review. Othermethods for confirming the reviews and/or quality checks may bepossible.

Referring again to FIG. 1, the method 100 may include recording thereview (step 114). For instance, information from the review may berecorded at the central server and/or at the host system. Suchinformation may include digital photograph(s), geographic coordinate(s),field data collected during the review, input relating to the firstquality check, input relating to the second quality check, inputrelating to the third quality check, and so on. Such records may provideelectronic documentation of the review conducted for the agent location.In another aspect, the central server and/or the host system maygenerate a score indicating a successful completion of the review. Thescore may be determined based on any of combination or piece ofinformation related to the review. For example, the score may be basedon the first quality check being successfully completed. The score mayindicate successful completion of the review and mark that the review isclosed. In another aspect, a successful score may permit the FTF toproceed in the routing to review a different agent location.

Still, in another aspect of FIG. 1, the method 100 may include sendingthe review to the host system of the MSB (step 116). For example, thecentral server may transmit the information from the review to the hostsystem corresponding to the MSB. The host system may analyze theinformation from the review to determine a subsequent action item forthe agent location and/or for the third party vendor. Such subsequentaction items may include implementing an agent employee trainingprotocol, whereby the agent employee training protocol is selected bythe MSB to address any non-compliances predicted by the field-dataobtained in the questionnaire. Other action items may comprise furtherinstructions and/or training for the staff at the third party vendor,including the FTF, the QC consultant, the chartered accountant, and/orother members. For example, the central server may receive feedbackdirected to a FTF training action from a host system of the MSB. Thefeedback may be based at least in part on the information from thereview. The central server may further notify the FTF via the mobiledevice of the FTF regarding the feedback, and/or provide the FTFtraining action. In some cases, such training actions may be identifiedand implemented promptly prior to the FTF continuing to a next locationfor review.

Other steps may be possible. For example, MSB and/or third party vendormay verify or re-verify the agent location as a fourth quality check. Asa fourth quality check, the host system and/or central server mayconfirm that the FTF and/or the agent is at the correct agent locationaccording to sampling data collected at the review and/or to a moneytransfer control number (“MTCN”), or other unique transaction referencenumber, that is collected at the agent location during the initialreview. Such data may be collected by the mobile device via the mobileapplication and made available to the host system and/or the third partyvendor. In one example, the MSB host system retrieves MTCNs from variousreviews on a regular basis, such as weekly or monthly basis, and mapsthe agent locations associated with the MTCNs to confirm if the FTFand/or the agent are actually at the correct location during the review.In a different aspect, the MSB host system may collect the geographiccoordinates from the review(s) to generate a mapping of agent locations.For instance, the geographic coordinates may be provided to a marketingoperations team of the MSB, which may utilize the data to help customersidentify an agent location closest to their location, work place,residence, or place of stay, or which is otherwise convenient to access.Such mapping and/or data may be searchable and provided on a website ofthe MSB.

Turning now to FIG. 2, a block diagram of an example system 200 in whichall or portions of the method 100 may be implemented is shown. Theexample system 200 may include a money transfer provider or a MSB 202having a host system 204, such as a system operated by WESTERN UNION oranother money transfer provider service that may be capable ofperforming a variety of consumer-based money transfer transactions frompayers (senders) to payees (recipients). Merely by way of example, theMSB 202 may facilitate wire transfers and bill payment transactions,among other products and services that may be provided.

It is noted that the MSB 202 may be in operative communication withvarious source and destination accounts (not shown) of senders andpayers, respectively, to allow for money transfer transactions to occur.The MSB 202 may maintain, control, and/or otherwise manipulate suchaccounts. Merely by way of example, the source account may be any of avariety of accounts, such as a traditional bank account provided for bya financial institution. In another example, the source account may be avirtual (or e-money) wallet which may be provided for by a mobileoperator or agent. Similarly, the destination account may be any of avariety of accounts, such as a bank or virtual (e-money) account, and adestination account provider may be a financial institution, mobileoperator, or agent accordingly. In other examples, products and servicesof the MSB 202 may be provided via various agent and representativelocations. For instance, a recipient of a money transfer may receive thetransferred money in cash at a regular agent location. Such agents maycomprise an individual, group, retail location, or other entity thatallows customers to access services of the MSB 202. Generally speakingand as understood by one skilled in the art, the MSB 202 may access asource account of one account provider and/or a destination account ofthe same or a different account provider to affect a transfer fromand/or to the accounts. Such transfer may be completed via a financialtransfer network, which may be one of the networks represented bynetwork 206.

The MSB 202, and/or more particularly the host system 204 thereof, maybe communicatively coupled to one or more networks 206, such as awireless communications network, a financial transaction network, theInternet, a cellular network, and the like. Also communicatively coupledwith one or more of the networks 206 may be one or more third partyvendors 208 that are appointed or otherwise utilized by the MSB 202 forfacilitating compliance reviews of agent locations. In one example, thenetwork 206 comprises a cellular network for data and/or phonecommunication between the host system 204 and the central server system210. Although a single third party vendor 208 is shown, it is noted thatthe MSB 202 may utilize a plurality of third party vendors 208, wherebyeach third party vendor may include a central server system 210.

The host system 204 and/or the central server 210 may further becommunicatively coupled to a plurality of agent locations 212 a,b,c viaone or more networks 206. Each agent location 212 a,b,c may begeographically dispersed and/or located remotely from one another, aswell as from the central server 210 and the host system 204. Asdescribed above, the agent locations 212 a,b,c may form a network forthe MSB 202 in which products and services of the MSB 202 aredistributed there-through. Although only three agent locations 212 a,b,care shown for simplicity, numerous agent locations may be operativelyconnected to the host system 204 and/or the central server system 210via one or more different types of networks 206. Merely by way ofexample, the MSB 202 may operate through a network of hundreds ofthousands of agent locations.

Each agent location 212 a,b,c may include an agent system 214 a,b,c,such as a computer system that is operatively connected to one or morenetworks 206. In one example, the agent system 214 a,b,c is operativelyconnected to a cellular network for data and/or phone communication withthe host system 204 and/or the central server system 210. As furthershown in FIG. 2, a FTF mobile device 216 a,b,c (or any mobile device)such as a mobile phone and/or tablet, may be located at the agentlocation 212 a,b,c while a review is taking place, e.g. when a FTF islocated at the agent location 212 a,b,c while conducting a review. It isnoted that although a single FTF mobile device 216 a,b,c is shown foreach agent location 212 a,b,c, any number of FTF mobile devices 216a,b,c may be located on the premises of each agent location 212 a,b,c.FTF or other staff may be assigned a single device, and may be used atdifferent locations for different reviews. Each FTF mobile device 216a,b,c may provide, among other hardware and software elements, a mobileapplication that is configured to conduct reviews, such as a proprietarycompliance review mobile application that is created, modified, and/orotherwise generated by the MSB 202 and/or the central server 210. EachFTF mobile device 216 a,b,c may be operatively connected to the hostsystem 204 and/or the central server system 210 via one or more wirelesscommunications networks 206 to permit sending and/or receiving data,such as field-visit data, phone calls, and the like. Further, it isnoted that although not explicitly shown, the FTF mobile device 216a,b,c may be in operative communication with any other FTF mobiledevices and/or agent location systems 214 a,b,c.

As further shown in FIG. 2, a compliance review engine 218 may beprovided at the central server system 210 and/or the host system 204. Insome examples, the compliance review engine 218 may communicate with theFTF mobile device 216 a,b,c and/or more specifically, the compliancereview mobile applications provided thereon, to conduct various steps ofthe review process as exemplified in the method 100. For instance, thecompliance review engine 218 may initiate and/or otherwise participatein receiving review data from the FTF mobile devices 216 a,b,c and/orperforming various quality checks as discussed above.

It should be understood by one having ordinary skill in the art that thecommunicative links shown in FIG. 2 may include additional communicationnetworks and/or conduits. Communication channels may exist that are notexplicitly shown. Further, communications interfaces may be providedthrough a variety of means, which can include non-mobile networks, suchas fiber-optic, coaxial cable, and/or other hard-wired means. It will beunderstood by one having ordinary skill in the art that the system 200represents some embodiments of the invention, and that the inventionallows for a variety of other configurations.

Referring back to the compliance review mobile application of the FTFmobile device 216 a,b,c in FIG. 2, in some examples, the mobileapplication comprises an Android application that is utilized on anAndroid-supporting phone and/or tablet. The compliance review mobileapplication may serve as a mechanism for real-time quality checks and/orfollow-up actions. It is contemplated that the compliance review mobileapplication provides the questionnaire for collecting field-visit data.The questionnaire may be formatted per jurisdictional and/or countryrequirements. Further, the questionnaire may include a built-in scoringmatrix and/or escalation grid to aid in deciding any follow-up actionsthat should be pursued. Further, as described previously, the mobileapplication may geo-tag FTF visits of the agent location 212 a,b,c tomark attendance of the FTF online, at the correct agent location, andtrack FTF movements. Any data collected by the mobile application may besubmitted to the central server 210 and/or the host system 204 uponpressing a submission button, or soft key, on an interface of the mobileapplication.

Alternatively and/or additionally, a web application may be provided,such as by the central server 210 and/or the host system 204 tofacilitate capture of data in situations where the FTF mobile device 216a,b,c is unavailable, down, and/or damaged. In that case, the webapplication 220 may comprise a webpage that is accessible via a laptopor a computer. In a different example, the mobile application mayprovide offline capture of field-visit data, whereby any collectedinformation is retained by the FTF mobile device 216 a,b,c in case thereis a system/network outage. Data security measures, such as encryption,decryption, encoding, and decoding schemes, may be implemented tofacilitate the safe retention of the collected information. In adifferent aspect, the mobile application may include multiplequestionnaire formats with independent scoring mechanisms.

Turning now to FIG. 3, a flow chart is shown illustrating anotherexample method 300 for identifying and mitigating risks relating toAML/KYC non-compliances. The method 300 may be performed by the centralserver of the third party vendor in operative communication with a FTFmobile device and/or a MSB host system. The method 300 may includeidentifying an agent location for review (step 302) and/or engaging anexternal vendor for reviewing the agent location (step 304). In oneexample, steps 302 and 304 are performed by the MSB host system. Themethod 300 may further include assigning a FTF to visit the agentlocation for review. For example, the third party vendor may select theFTF for reviewing the agent location. It is noted that although a singleagent location is being described herein, a plurality of agent locationsmay be identified and/or assigned to a single FTF, and/or a plurality ofFTFs, and evaluated for review following the method 300.

The method 300 may further include receiving data collected during thereview by the deployed FTF. For instance, the central server of theexternal vendor may receive responses entered in an objectivequestionnaire that is provided on a mobile application of a mobiledevice of the FTF, as described in the foregoing paragraphs (step 308).The central server may also receive digital photograph(s) and/orgeographic coordinates relating to the agent location, as captured bythe mobile application (step 310). Such data may also be sent by the FTFmobile application to the host system of the MSB.

Upon receiving the data, the central server and/or the host system mayqueue up the data for review by a Quality Check (QC) consultant toperform one or more real-time quality checks for the review conducted atthe agent location (step 312). If any issue are identified (step 314),the QC consultant accessing the central server and/or the host systemdata may contact the FTF (step 316) immediately to implement anynecessary training that is based on determinations from the qualitycheck(s) and/or to implement any corrective measures to the agentlocation in real-time. Upon contacting the FTF and successfullyaddressing the issues identified, or if no issues are identified withthe review, the review may be recorded at the central server and/or thehost system (step 318). In another example, the review may be scoredand/or marked as successfully completed to close a real-time portion ofthe quality check, such as upon completion of the first quality check.In other examples, the review is not marked as successfully completeduntil subsequent quality checks are performed.

As shown in the method 300, further quality checks may include, and arenot limited to, a review by a chartered accountant. For instance, thecentral server of the third party vendor may initiate the quality checkby the chartered accountant (step 320). If the review and/or firstquality check results are recorded at the central server, the centralserver may transmit and/or otherwise provide access to the informationfor the chartered accountant. The chartered accountant may ensure, amongother tasks, that the third party vendor system is operating properly,identify any training that may be needed for the FTF and/or QCconsultants of the third party vendor system, among otherresponsibilities. In another example, the central server initiatesfurther quality check(s) (step 322) for the review. Such quality checksmay include, but are not limited to, periodic comparisons of the currentreview to previous reviews of the agent location, flagging the reviewfor further quality checks to be performed by the MSB host system, andother possibilities.

In practice, it is contemplated that the above method 300 may facilitatethe review process for compliance issues in a number of ways, such asproviding a method for the MSB to validate the visits in real-time toensure that the external vendor is providing a quality review service.For instance, the mobile application may geo-tag the field-visit dataand/or the digital photograph(s) in order to mark an attendance of theFTF as being online, being located at the correct agent location, andfor tracking FTF movements along an assigned route. Such geo-tags may beused in similar manners to validate subsequent visits. In anotheraspect, one or more digital photographs are taken via the mobileapplication and transmitted along with the review information to confirmvisits. In other aspects, confirmation of training imparted by the FTFand/or otherwise received by an agent at the agent location may beprovided via a seal that is affixed to a physical and/or electronicdata, whereby the seal may confirm that the FTF visited the correctlocation. As another measure for verifying the reviews, the third partyvendor may include supervisors that separately review a small percentageof cases that are randomly selected in order to match the responses ofthe quality check(s) with previous responses from previous qualitycheck(s) to identify any deficiencies. In other examples, uniquetransaction reference numbers may be collected during visits by the FTF.Such reference numbers may be utilized by the MSB to validate whetherthe FTF visited the correct location, and may be conducted online orexternally. It is noted that any of these validation procedures may beperformed by the MSB host system and/or the third party vendor centralserver.

To expand further on the location review process of method 300, it isnoted that the MSB host system may utilize a volume risk-based matrix toidentify which agent locations should be assigned for review by thethird party vendor. The volume risk-based matrix may consider a volumeof products and services being offered through a particular agentlocation, and/or a risk level for the particular agent location. Suchrisk levels may be obtained from previous reviews and/or quality checksassociated with the agent location, and/or triggers or flags arisingfrom recent activity at the agent location. Other examples are possible.The identified agent locations for review may be provided to theexternal vendor that determines a routing and list of locations that maybe covered by the FTF.

It is further noted that the mobile application utilized by the FTF mayprovide the FTF with details from a previous review performed by theFTF, and/or performed at the agent location being investigated. Suchcapabilities may aid in confirming if previous issues have beenaddressed. A case history may also be provided via the mobileapplication for similar purposes. In another aspect, the mobileapplication, and/or the mobile device itself, may initiate and/orreceive real-time emails or messages. Merely by way of example, theexternal vendor, via the central server, may initiate real-time messagesto alert or update agents at the agent location and/or in-house staff atthe MSB. In an aspect, the real-time operations of the mobileapplication may serve as an agent verification tool that facilitates intracking a physical location and/or responsiveness of an agent at theagent location.

Turning to FIG. 4, an example communications sequence 400 for the system200 of FIG. 2 is provided. Specifically, the communications sequence 400illustrates a possible approach for conducting a review on an agentlocation according to various embodiments of the present disclosure. TheFTF mobile device 216 a the external vendor central server 210, and theMSB host system 204 are illustrated. It is noted that other sequencesand/or steps may be included, alternatively and/or additionally, to thesequence 400. It is also noted that the specific FTF mobile device 216 ais shown merely for example purposes, and that any FTF mobile device maybe utilized. Further, some or all of the steps may be partially and/orfully automated, and/or involve manual input.

As shown in the sequence 400, the host system 204 may determine an agentlocation for review (302). Upon determining the agent location forreview, the host system 204 may send the determined agent location tothe central server 210 (304) of the appointed external vendor, or bysome other communication. In some examples, a plurality of agentlocations are identified for review and sent to the external vendor. Theexternal vendor may assign the review for each agent location to one ormore FTF (306) and send corresponding review instructions (308) to theFTF mobile device 216 a,b,c. Such review instructions may includedetails such as a time and date for conducting the review, the agentlocation to be reviewed, and/or other details, including the address ofthe location, that may be uploaded to the mobile device 216 a, and/ormore particularly the mobile application on the mobile device forconducting the review. It is contemplated that such data may beelectronically transmitted via a wireless network, such as a cellularcommunications network. In some cases, the FTF mobile device 216 a maysend, per request by the central server 210, confirmation that thereview instructions have been received and understood.

Subsequently, the FTF may take the FTF mobile device on-site to theagent location to obtain field-visit data for the review (310). Forinstance, the field-visit data may be captured on the mobile applicationvia a questionnaire format, and/or a physical form. In some examples,the mobile application may not allow the questionnaire to be accessibleon the mobile device 216 a until the mobile application determines,based on geographic coordinates identified by the mobile device 216 a,that the FTF mobile device is physically at the agent location. Uponcompleting the questionnaire, the FTF may scan a copy of the physicalform, if any, via the mobile application, and/or take a photograph ofthe location via the mobile application. The mobile application mayfurther geo-tag the photograph. The mobile application may provide asubmission button that when activated by the FTF begins streaming thecollected field-visit data to the external vendor server 210 (312).

Upon receiving the streamed field-visit data at the central server 210,a series of quality checks may be performed. A first quality check maybe performed (314) by a QC consultant that reviews the informationcaptured in the review and searches for any inconsistences in theinformation. Such inconsistencies may include inconsistent responses forvarious questions that are interlinked in the questionnaire, geographiccoordinates that do not match with known geographic coordinates of theagent location, a digital photograph quality and/or error, and so on.Other examples are possible. Upon identifying any inconsistencies, theQC consultant, via phone or the central server 210, may contact the FTF,via the mobile device 216 a, to make corrections, seek clarification,and/or provide any training (316). In some cases, any changes made bythe QC consultant may be recorded in an audit log at the central server210. In other cases, the QC consultant may require a new review to beperformed by the FTF. The mobile device 216 a may provide confirmationthat the corrections and/or training is performed, for instance in aback-and-forth relay over telephonic communications, emails, messages,and/or other communications sent directly via the mobile application.Once all of the identified issues have been addressed, the review may bescored as successful and/or unsuccessful, and/or various levels thereof,and then recorded at the central server 210 (320), and/or closed. Insome examples, the review remains open until the QC consultant finishesreviewing the submission under the first quality check. The FTF may begranted permission, upon closing the review, to continue to other agentlocations to conduct other reviews.

As illustrated in FIG. 4, in the present example, sequences includedwithin a dashed territory 322 are performed in real-time, withoutsignificant lag. Real-time access to information is provided to allowfor quick decision-making and/or analysis, thereby preventing ormitigating possible risks associated with non-compliances that areidentified by the review. To consider another aspect, such processesalso ensure data integrity since once saved at 320, no changes arepossible by the FTF and therefore the likelihood of any possiblecollusion between the FTF and the agent location staff is reduced. It isnoted that other sequences may be performed in real-time as well.

Further shown in sequence 400, central server 210 may continueperforming various quality checks on the review after it is closed(324). Such quality checks may include any of the quality checksidentified above, such as those performed by a chartered accountant thatvalidates the review of the FTF, and/or reviews performed by supervisorsfor consistency with previously conducted reviews. The review and/orquality check(s) may be transmitted to the MSB host system 204 (326),which may then analyze the review for any risks, whether a correct agentlocation was visited, and/or determine any further training that the FTFand/or QC consultant may benefit from (328). The host system 204 maycommunicate such feedback, such as training feedback (330) to thecentral server 210. In response, the central server 210 and/or otherentity may provide the training stipulated by the MSB to the QCconsultant(s) (332) and/or to the FTF (334).

Turning now to FIG. 5, a block diagram is shown illustrating a computersystem upon which embodiments of the present invention may beimplemented. This example illustrates a computer system 500 which as maybe used, in whole, in part, or with various modifications, to providethe functions of the FTF mobile device 216 a,b,c, mobile application,agent system 214 a,b,c, central server 210, host system 204, compliancereview engine 218, and/or other components and features of the inventionsuch as those discussed in FIGS. 1-4.

The computer system 500 is shown comprising hardware elements that maybe electrically coupled via a bus 590. The hardware elements may includeone or more central processing units 510, one or more input devices 520(e.g., a mouse, a keyboard, etc.), and one or more output devices 530(e.g., a display device, a printer, etc.). The computer system 500 mayalso include one or more storage device 540. By way of example, storagedevice(s) 540 may be disk drives, optical storage devices, solid-statestorage device such as a random access memory (“RAM”) and/or a read-onlymemory (“ROM”), which can be programmable, flash-updateable and/or thelike.

The computer system 500 may additionally include a computer-readablestorage media reader 550, a communications system 560 (e.g., a modem, anetwork card (wireless or wired), an infra-red communication device,Bluetooth™ device, cellular communication device, etc.), and workingmemory 580, which may include RAM and ROM devices as described above. Insome embodiments, the computer system 500 may also include a processingacceleration unit 570, which can include a digital signal processor, aspecial-purpose processor and/or the like.

The computer-readable storage media reader 550 can further be connectedto a computer-readable storage medium, together (and, optionally, incombination with storage device(s) 540) comprehensively representingremote, local, fixed, and/or removable storage devices plus storagemedia for temporarily and/or more permanently containingcomputer-readable information. The communications system 560 may permitdata to be exchanged with a network, system, computer and/or othercomponent described above.

The computer system 500 may also comprise software elements, shown asbeing currently located within a working memory 580, including anoperating system 584 and/or other code 588. It should be appreciatedthat alternate embodiments of a computer system 500 may have numerousvariations from that described above. For example, customized hardwaremight also be used and/or particular elements might be implemented inhardware, software (including portable software, such as applets), orboth. Furthermore, connection to other computing devices such as networkinput/output and data acquisition devices may also occur.

Software of computer system 500 may include code 588 for implementingany or all of the function of the various elements of the architectureas described herein. For example, software, stored on and/or executed bya computer system such as system 500, can provide the functions of anyof the print function applet, and/or other components of the inventionsuch as those discussed above.

Turning now to FIG. 6, a block diagram illustrating an exampleprocedural flow 600 for an agent oversight program directed toidentifying and mitigating risks relating to AML/KYC non-compliances isillustrated. The flow 600 includes steps that are performed by the MSB602 and the external vendor 604, and communications there-between. Asshown, the MSB may identify agent locations for review (step 606) andhandover, or otherwise electronically transmit, the locations to theappointed external vendor (step 608). The external vendor may assign theidentified agent locations for its FTF to review (step 610). The FTF mayselect or otherwise initiate the review of the agent location (step 612)by first visiting the agent location (step 614) with an Android-basedmobile device. Using the mobile device, the FTF may perform the reviewaccording to various steps highlighted in box 616.

The FTF may determine if the agent location is available for review(step 618), e.g. the agent location is open and operating rather thanclosed. If the agent location is not available, the FTF may take aphotograph of the agent location using the mobile application and/orescalate the case to the MSB (620). For instance, a notification may besent from the mobile application to the central server of the externalvendor and/or the MSB indicating the escalation. The mobile device mayfurther capture geo-coordinates as verification that the FTF hasassessed the correct agent location. In some cases, escalating the casemay flag the agent location and set up a reminder in the mobileapplication for the FTF to reschedule its visit for a later date. It iscontemplated that the agent location is not typically informed of theFTF visiting dates, though it is likely in some such cases the FTF mayagree upon a time/date to ensure a review is completed. In some cases,the reason for closure could trigger other actions (for examplesuspension of the location by the MSB, etc.).

The FTF may determine that the agent location is available for review,and proceed to conduct the review. The FTF may enter findings into themobile application (step 622) and/or enter the findings into a paperquestionnaire (step 624). The FTF may further train the staff at theagent location and get a physical signature (step 626) on the paperquestionnaire from the staff as verification that training was performedand/or evaluation was completed. If any issues are identified by theFTF, such as inconsistent answers in the questionnaire, the issues maybe addressed (step 628) on-site. The physical questionnaire may bescanned and stored at the central server and/or at the MSB (step 630).In some cases, the mobile application scans, stores, and transmits thephysical form to the central server and/or the MSB host systemaccordingly.

Additionally and/or alternatively, the findings may be entered in amobile application provided on the mobile device or tablet of the FTF(step 622). After filling out the questionnaire, the FTF may use themobile application to take a digital photograph of the agent location(step 632), capture the geo-coordinates of the agent location, andstream the information to the central server of the third party vendorfor review. In some examples, the geographic coordinates are capturedupon submission of the information to the central server, e.g. uponpressing a submit button in the mobile application, to possibly verifythat the FTF has not yet left the agent location prior to closing thecase. The central server may receive the streamed information inreal-time and initiate a quality check, such as a first quality check bya QC consultant or a team thereof (step 634). If any issues areidentified (step 636), the issues may be immediately addressed by theteam by calling the FTF, clarifying with the FTF, and/or training theFTF (step 638). Once the issues are addressed, or if there are no issuesidentified in the quality check of the review, the review and/or qualitycheck results may be recorded on the central server (step 640). Thesuccessful reviews may be scored (step 642) and closed to permit the FTFto proceed to a next agent location. Unsuccessful reviews may be markedas unsuccessful and remain open until all identified issues areresolved. It is contemplated that any reviews recorded on the server maybe pulled by the MSB at any time to evaluate any further actions (suchas training the agent location on specific aspects of a particularquestion that has been marked as a defect).

The external vendor may perform additional quality checks, such asassigning the cases for review by a chartered accountant (step 644),which may identify any training needed for the FTF that conducted theagent location review and/or the QC consultant(s) that performed thefirst quality check. In another example, the external vendor may assigna portion of the cases, such as 10% of the cases, for an additionalquality check (step 646). Such quality checks may include/allow, merelyby way of example, comparing the review with previous reviews toidentify any inconsistencies and/or changes therewith.

As shown in FIG. 6, the MSB may utilize the successful reviews obtainedfrom the central server of the external vendor for furthercompliance-related analysis and/or actions (step 648), such asgenerating risk reports for further analysis (step 650) and/or emailingin-house staff and/or agents of determined actions to be implemented(step 652). In another aspect, the MSB may utilize the data collected inthe review for various internal actions (step 654), which may includequality checks, among others. Merely by way of example, the MSB mayutilize an MTCN collected during the review to confirm if the correctagent location was visited (step 656). The MSB may analyze specificreviews for further actions (step 658). The MSB may perform additionalquality checks based on pre-defined criteria (step 660). Further, theMSB may select agent locations for physical visits by the MSB in-housestaff (step 662). In another aspect, the MSB may utilize the reviews tovalidate address and contact numbers of agent locations for correctness.Based on the various analysis processes performed at the MSB, the MSBmay determine and provide feedback for training the FTF of the thirdparty vendor (step 664) in preparation for future visits. It is notedthat some agent locations may be reviewed once in a quarter, twiceannually, once per year, and/or at other frequencies, which may bechanged based on the review(s) and quality checks and/or of the assessedrisk of the specific locations. In some examples where agent locationsare reviewed only once annually, if the systems and methods disclosedherein predict that the agent location is in a high risk category, theMSB may determine to re-review the location a month later or at agreater frequency. Other examples are possible.

In the foregoing description, for the purposes of illustration, methodswere described in a particular order. It should be appreciated that inalternate embodiments, the methods may be performed in a different orderthan that described. It should also be appreciated that the methodsdescribed above may be performed by hardware components or may beembodied in sequences of machine-executable instructions, which may beused to cause a machine, such as a general-purpose or special-purposeprocessor or logic circuits programmed with the instructions to performthe methods. These machine-executable instructions may be stored on oneor more machine readable mediums, such as CD-ROMs or other type ofoptical disks, floppy diskettes, ROMs, RAMs, EPROMs, EEPROMs, magneticor optical cards, flash memory, or other types of machine-readablemediums suitable for storing electronic instructions. Alternatively, themethods may be performed by a combination of hardware and software.

While illustrative and presently preferred embodiments of the inventionhave been described in detail herein, it is to be understood that theinventive concepts may be otherwise variously embodied and employed, andthat the appended claims are intended to be construed to include suchvariations, except as limited by the prior art.

What is claimed:
 1. A system comprising: one or more processing devicescomprising one or more processors; and memory communicatively coupledwith the one or more processors and having stored thereinprocessor-readable instructions that, when executed by the one or moreprocessors, cause the one or more processing devices to perform:processing an indication of an agent system received via one or morenetworks; determining a location corresponding to the agent system basedat least in part on the indication of the agent system received via theone or more networks; initiating a session with a mobile devicewirelessly connected to the system via the one or more networks;remotely directing in real time at least a first operation correspondingto the agent system to comply with a set of rules associated with thelocation at least in part by the initiating the session with the mobiledevice wirelessly connected to the system via the one or more networks;causing communicating to the mobile device while the session with themobile device is taking place to activate a camera feature of a mobileapplication on the mobile device to capture a first digital photographduring the session; collecting a set of data with respect to the agentsystem, the set of data comprising the first digital photograph;analyzing the set of data collected by the system that comprises thefirst digital photograph, where the analyzing the set of data isperformed during the session; and performing a verification process withrespect to the agent system during the session, where the verificationprocess is based at least in part on the analyzing the set of datacollected by the system that comprises the first digital photograph. 2.The system as recited in claim 1, the one or more processing devices tofurther perform: based at least in part on one or more results of theverification process, remotely directing at least a second operationcorresponding to the agent system where the second operationcorresponding to the agent system is performed during the session. 3.The system as recited in claim 2, where the second operationcorresponding to the agent system corresponds to controlling the agentsystem.
 4. The system as recited in claim 3, where the controlling theagent system corresponds to suspending or terminating one or moreoperations of the agent system.
 5. The system as recited in claim 1, theone or more processing devices to further perform: configuringspecifications of content items and formatting of interface elements toconform to the set of rules associated with the location; and initiatinga data retrieval process to retrieve field data from the mobile deviceat least partially by transmitting the specifications of the contentitems and the formatted interface elements to the mobile device, thedata retrieval process comprising real-time evaluation of input andselecting one or more content items and one or more correspondinginterface elements during the data retrieval process based at least inpart on the real-time evaluation.
 6. The system as recited in claim 1,the one or more processing devices to further perform: generating amapping of geographic coordinates based at least in part on a firstplurality of geographic coordinates received from the mobileapplication, wherein each of the first plurality of geographiccoordinates correspond to a first location where the first digitalphotograph was captured during the session and each of the firstplurality of geographic coordinates are associated with a first time;where the analyzing the set of data collected by the system comprisesanalyzing the first plurality of geographic coordinates and the fielddata; based at least in part on the analyzing, determining one or moresubsequent actions for performance with respect to the agent system; andcausing the one or more subsequent actions for performance with respectto the agent system.
 7. The system as recited in claim 1, the one ormore processing devices to further perform: processing first field datafrom the mobile application received during the session; responsive tothe receiving the first field data, reinitiating the camera feature ofthe mobile application of the mobile device to capture a second digitalphotograph associated with a geographic coordinate or a secondgeographic coordinate at during the session; processing a second digitalphotograph from the mobile application on the mobile device; processingsecond field data from the mobile application during the session;querying associated memory to locate a second plurality of geographiclocations associated with a second location, the second plurality ofgeographic locations being associated with a second time, the secondtime being prior to the first time; and comparing, at the server system,a first plurality of geographic locations associated with the firstlocation to the second plurality of geographic locations associated withthe second location to determine that the first location is the secondlocation.
 8. A method comprising: processing, by a system comprising oneor more processors, an indication of an agent system received via one ormore networks; determining, by the system, a location corresponding tothe agent system based at least in part on the indication of the agentsystem received via the one or more networks; initiating, by the system,a session with a mobile device wirelessly connected to the system viathe one or more networks; remotely directing in real time, by thesystem, at least a first operation corresponding to the agent system tocomply with a set of rules associated with the location at least in partby the initiating the session with the mobile device wirelesslyconnected to the system via the one or more networks; causing, by thesystem, communicating to the mobile device while the session with themobile device is taking place to activate a camera feature of a mobileapplication on the mobile device to capture a first digital photographduring the session; collecting, by the system, a set of data withrespect to the agent system, the set of data comprising the firstdigital photograph; analyzing, by the system, the set of data collectedby the system that comprises the first digital photograph, where theanalyzing the set of data is performed during the session; andperforming, by the system, a verification process with respect to theagent system during the session, where the verification process is basedat least in part on the analyzing the set of data collected by thesystem that comprises the first digital photograph.
 9. The method asrecited in claim 8, further comprising: based at least in part on one ormore results of the verification process, remotely directing at least asecond operation corresponding to the agent system where the secondoperation corresponding to the agent system is performed during thesession.
 10. The method as recited in claim 9, where the secondoperation corresponding to the agent system corresponds to controllingthe agent system.
 11. The method as recited in claim 10, where thecontrolling the agent system corresponds to suspending or terminatingone or more operations of the agent system.
 12. The method as recited inclaim 8, further comprising: configuring specifications of content itemsand formatting of interface elements to conform to the set of rulesassociated with the location; and initiating a data retrieval process toretrieve field data from the mobile device at least partially bytransmitting the specifications of the content items and the formattedinterface elements to the mobile device, the data retrieval processcomprising real-time evaluation of input and selecting one or morecontent items and one or more corresponding interface elements duringthe data retrieval process based at least in part on the real-timeevaluation.
 13. The method as recited in claim 8, further comprising:generating a mapping of geographic coordinates based at least in part ona first plurality of geographic coordinates received from the mobileapplication, wherein each of the first plurality of geographiccoordinates correspond to a first location where the first digitalphotograph was captured during the session and each of the firstplurality of geographic coordinates are associated with a first time;where the analyzing the set of data collected by the system comprisesanalyzing the first plurality of geographic coordinates and the fielddata; based at least in part on the analyzing, determining one or moresubsequent actions for performance with respect to the agent system; andcausing the one or more subsequent actions for performance with respectto the agent system.
 14. The method as recited in claim 8, furthercomprising: processing first field data from the mobile applicationreceived during the session; responsive to the receiving the first fielddata, reinitiating the camera feature of the mobile application of themobile device to capture a second digital photograph associated with ageographic coordinate or a second geographic coordinate at during thesession; processing a second digital photograph from the mobileapplication on the mobile device; processing second field data from themobile application during the session; querying associated memory tolocate a second plurality of geographic locations associated with asecond location, the second plurality of geographic locations beingassociated with a second time, the second time being prior to the firsttime; and comparing, at the server system, a first plurality ofgeographic locations associated with the first location to the secondplurality of geographic locations associated with the second location todetermine that the first location is the second location.
 15. One ormore machine-readable storage devices for storing machine-executableinstructions that, when executed by one or more processing devices,cause the one or more processing devices to perform operationscomprising: processing an indication of an agent system received via oneor more networks; determining a location corresponding to the agentsystem based at least in part on the indication of the agent systemreceived via the one or more networks; initiating a session with amobile device wirelessly connected to the system via the one or morenetworks; remotely directing in real time at least a first operationcorresponding to the agent system to comply with a set of rulesassociated with the location at least in part by the initiating thesession with the mobile device wirelessly connected to the system viathe one or more networks; causing communicating to the mobile devicewhile the session with the mobile device is taking place to activate acamera feature of a mobile application on the mobile device to capture afirst digital photograph during the session; collecting a set of datawith respect to the agent system, the set of data comprising the firstdigital photograph; analyzing the set of data collected by the systemthat comprises the first digital photograph, where the analyzing the setof data is performed during the session; and performing a verificationprocess with respect to the agent system during the session, where theverification process is based at least in part on the analyzing the setof data collected by the system that comprises the first digitalphotograph.
 16. The one or more machine-readable storage devices asrecited in claim 15, the operations further comprising: based at leastin part on one or more results of the verification process, remotelydirecting at least a second operation corresponding to the agent systemwhere the second operation corresponding to the agent system isperformed during the session.
 17. The one or more machine-readablestorage devices as recited in claim 16, where the second operationcorresponding to the agent system corresponds to controlling the agentsystem.
 18. The one or more machine-readable storage devices as recitedin claim 17, where the controlling the agent system corresponds tosuspending or terminating one or more operations of the agent system.19. The one or more machine-readable storage devices as recited in claim15, operations further comprising: configuring specifications of contentitems and formatting of interface elements to conform to the set ofrules associated with the location; and initiating a data retrievalprocess to retrieve field data from the mobile device at least partiallyby transmitting the specifications of the content items and theformatted interface elements to the mobile device, the data retrievalprocess comprising real-time evaluation of input and selecting one ormore content items and one or more corresponding interface elementsduring the data retrieval process based at least in part on thereal-time evaluation.
 20. The one or more machine-readable storagedevices as recited in claim 15, operations further comprising:generating a mapping of geographic coordinates based at least in part ona first plurality of geographic coordinates received from the mobileapplication, wherein each of the first plurality of geographiccoordinates correspond to a first location where the first digitalphotograph was captured during the session and each of the firstplurality of geographic coordinates are associated with a first time;where the analyzing the set of data collected by the system comprisesanalyzing the first plurality of geographic coordinates and the fielddata; based at least in part on the analyzing, determining one or moresubsequent actions for performance with respect to the agent system; andcausing the one or more subsequent actions for performance with respectto the agent system.